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BFCSA investigates fraud involving lenders, spruikers and financial planners worldwide.  Full Doc, Low Doc, No Doc loans, Lines of Credit and Buffer loans appear to be normal profit making financial products, however, these loans are set to implode within seven years.  For the past two decades, Ms Brailey, President of BFCSA (Inc), has been a tireless campaigner, championing the cause of older and low income people around the Globe who have fallen victim to banking and finance scams.  She has found that people of all ages are being targeted by Bankers offering faulty lending products. BFCSA warn that anyone who has signed up for one of these financial products, is in grave danger of losing their home.


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BFCSA: Dear Mr Prime Minister Rank Misrepresentation in Aged People’s Accommodation Promotion # 36

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The Hon Scott Morrison MP
Prime Minister Parliament House

July 20, 2019

Rank Misrepresentation in Aged People’s Accommodation Promotion: An Appeal for Restitution

Dear Mr. Morrison,

I am writing out of concern for the hundreds of retired people who have been defrauded by the actions of Sterling New Life and its parent company Sterling First (Aust) Limited of 19 Lyall Street, South Perth, WA 6151, which is now in Administration with over $20 million of investors’ money missing.

Founded in 2011, Sterling First combined “the two disciplines of property and funds management … and pioneered a range of both investment and housing opportunities to suit a variety of different lifestyles and financial standings” (from Sterling First website).

Sterling First described the product it marketed to the public, Sterling New Life (SNL), as “an alternative to traditional downsizing options which would result in real cash being freed up for living a more comfortable life in retirement.”

In good faith retiree investors paid in advance the rent for 40 years of tenancy (up to $325,000) as their ingoing for a home. Their good faith was met by what The West Australian (5 June 2019) reported as “allegations of misleading or deceptive conduct, unconscionable conduct and breaches of contract”.

Included in the misrepresentations made to these elderly people were:

  1. They believed that the funds they contributed were secured. But the Sterling Group provided no warranty on the product they were selling.
  2. Purchasers were not informed that SNL was one of eleven companies under the Sterling First umbrella, nor that their ingoing funds, which constituted the major part of most couples’ life savings, were distributed untraceably through the multilayered web of overlapping and interdependent Sterling First Group entities, many of which were trading with ongoing losses.
  3. These unsecured contributors were not informed that Sterling First used a significant fraction of their ingoing capital to pay the Group’s interest bill.
  4. Contributors were not informed of who owned the title to their home. Neither did Sterling disclose the complex ownership structure within which the rental properties were held.
  5. They were not told that the SNL they were buying into was the subject of an ASIC investigation for which Notices had been issued under the ASIC Act.
  6. The precarious solvency of the whole Sterling Group was withheld from purchasers.


This extraordinary information asymmetry suggests that the conditions for caveat emptor are abrogated, hence this appeal for restitution has a legal as well as a moral basis.


Mr. Morrison, I appeal to you to go beyond pursuing the Sterling First perpetrators of these fraudulent actions to utilising measures comparable to those enshrined in the Proceeds of Crime legislation to secure financial restitution for the SNL purchasers whose contributions have vanished.


Yours sincerely,




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